Articles/Publications

Stay in the know with Andreozzi Bluestein LLP

Articles/Publications

Stay in the know with Andreozzi Bluestein LLP

IRS Delinquent 1120F Campaign – Are You Prepared?

BY: LOU CARLOW The IRS has identified the failure to file Forms 1120-F as the most recent front for its enhanced campaign to enforce compliance.  This campaign sends a clear message to foreign ...

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How U.S. Foreign Information Reporting applies to Your Cross Border Holdings

by Buffalo Niagara Partnership As another filing season is upon us, it is important to be aware of the extensive information reporting associated with holding assets outside of the U.S.  Failing to ...

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Andreozzi Bluestein Attorneys Speak on Federal and State Compliance Issues

Buffalo Law Journal’s Michael Petro interviewed Andreozzi Bluestein’s Senior Associate Michael Tedesco and Associate Heather Schmidt on federal and state compliance issues for his Tax Law Special ...

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The Threat of Parallel Investigations: When Civil Isn’t Civil

While at one time, the IRS would discontinue a civil examination when it began a criminal investigation of a taxpayer, it is now the IRS’s policy in certain situations to conduct simultaneous ...

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Law Creates New Due Dates for FBAR and Other Tax and Informational Returns

On Friday, July 31, 2015, President Obama signed H.R. 3236, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 into law.  In addition to temporarily extending funding ...

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Taxpayer Advocate Service Criticizes IRS’s Offshore Voluntary Disclosure Programs in 2014 Congressional Report

To combat money laundering and evasion of U.S. income obligations through the use of offshore accounts, Congress imposed a requirement on all United States taxpayers to annually file a Report of ...

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FEDERAL COURT APPROVES U.S. GOVERNMENT ISSUANCE OF JOHN DOE SUMMONSES

A Federal Judge recently approved the Internal Revenue Service’s issuance of what is known as a “John Doe” summons¹ to several entities in the U.S who utilized the services of Sovereign ...

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RECENT REVISIONS TO THE IRS OFFSHORE VOLUNTARY DISCLOSURE PROGRAMS

Recent revisions to the IRS Offshore Voluntary Disclosure Programs illustrate that the Service is becoming more aggressive and less tolerant with those taxpayers who have not yet come forward to ...

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How to Help Clients with Unfiled Tax Returns

If you have a client who, for any number of reasons, has unfiled tax returns for previous years, helping him or her get back into compliance may not be as difficult as he or she fears that it will ...

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Matrimonial Law and the IRS

Federal tax law can impact virtually every area of legal practice.  For example, in debtor/credit law, certain property is protected from enforced collection, such as a 401K, IRA or homestead ...

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IRS Makes Significant Changes to the Offshore Voluntary Disclosure Program and Streamlined Voluntary Disclosure Program

On June 18, 2014, the Internal Revenue Service (“IRS”) announced significant changes to the offshore voluntary disclosure programs. As part of the announcement, the IRS has expanded the 2012 ...

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Aragona Trust: Passive Activity Losses, the Material Participation Exception, and the Medicare Tax

Generally speaking, most taxpayers, including individuals and trusts, are denied the use of their passive activity losses and credits to offset ordinary income under the passive activity loss ...

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Tax Anxiety – Good News & Bad News

With the upcoming hype surrounding taxes as April 15th approaches, anxiety increases for those in tax trouble. A significant number of people have been contacted by the taxing authorities about ...

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The 11th Circuit Court of Appeals Reverses Tax Court Ruling on Intervention in USVI Cases

On February 20, 2014, the United States Court of Appeals for the Eleventh Circuit released an opinion allowing the Government of the United States Virgin Islands (“USVI”) to intervene in three ...

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Department of Justice Reminds Swiss Banks That Time is Running Out to Participate in a Non-Prosecution Agreement

In a November 5, 2013 post in The Justice Blog, the United States Department of Justice (DOJ) Tax Division issued a reminder to Swiss Banks that their time is running out to enter into a ...

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Liens and Levies

By: Gregory D. Verdibello, Esq. Once a taxpayer’s liability has been formally recorded on the books and records of the Internal Revenue Service (“IRS”), the IRS may use one of its collection ...

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Offers in Compromise: A Guide

By: Royston Mendonza Overview Very simply, an Offer in Compromise (“Offer”) is where a Taxpayer “offers” a sum of money to the Internal Revenue Service (“IRS”) to “compromise” a tax ...

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There’s Always Something (the IRS) There to Remind Me

Dionne Warwick Bankruptcy Case Seeks to Discharge Taxes By: Daniel Brown “Wishin’ and Hopin’”[2] to discharge more than $10.2 million in taxes, Dionne Warwick filed a Chapter 7 personal ...

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The New York State Department of Taxation and Finance Grants Relief for Non-Filers

By: Gregory Verdibello Unfiled returns can create financial and emotional stress, and can cause criminal issues for many people. It seems that more and more people are failing to file their returns ...

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Shedding Some Light on the PFIC Regime

By: Kenneth A. Grossberg Today, United States investors in foreign corporations often find themselves with an unknown or unexpected problem.  In particular, investors in mutual funds organized ...

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Offers In Compromise With The IRS

By: Deborah J. Weber The Government, like other creditors, encounters situations where an account receivable cannot be collected in full (especially in the current economic climate) or there is a ...

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Appealing an IRS Audit Report

by Gary Bluestein Sometimes, for a variety of reasons, it is just not possible to settle a case at the examination level.  For income, estate or gift tax cases that do not settle at exam, time ...

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The Uniqueness of the Federal Tax Lien

What a Non-Tax Lawyer Should Know by Gary Bluestein Being a tax column, the focus is usually on intricate tax issues of concern to the tax lawyer or perhaps an accountant.  However, in the past, I ...

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Dealing with Wage Garnishments and Tax Liens

by Deborah J. Weber A federal tax lien is created when the following three things occur. Assessment Notice and Demand for Payment Non-payment The lien arises on the date of non-payment and relates ...

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Do You Have Unfiled Income Tax Returns?

by Deborah J. Weber For various reasons, you may not have filed your federal income tax return for this year or previous years.  You may not have filed because you expected a refund and you just ...

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Overview of Federal Tax Penalties & Abatement in the Collection Defense Area of Practice

by Gary Bluestein    Although there are approximately 150 penalties contained in the Internal Revenue Code, the primary focus of this article is on the most common penalties dealt with by the tax ...

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Relief From Joint Income Tax Liability: Then and Now

by Deborah J. Weber Although we have grown up with joint returns and joint and several liability, our current tax system existed for five years without joint returns (introduced in 1918) and for ...

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The Practitioner’s Guide To Federal Tax Penalties And How And When To Request Abatement

by Deborah J. Weber    There are approximately 150 penalties contained in the Internal Revenue Code.  This article is not intended to address every penalty contained in the Code, but rather, will ...

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IRS Statute of Limitations

By: Gary Bluestein There is no greater pitfall for a practitioner than missing an applicable statute of limitations for a client.  Professional judgment can usually be defended.  The style and ...

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Maintain Books & Records: Defending Clients’ Sales & Use Tax Audits Against NYS

by Deborah J. Weber Various new enforcement initiatives have been undertaken by the New York State Tax Department in the past year with many enforcement initiatives focused on sales and use tax audit ...

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